Thursday, October 24, 2013

Information concerning the civil penalties process is discussed in OFAC regulations
governing the various sanctions programs and in 31 CFR part 501. On November 9, 2009,
OFAC published as Appendix A to part 501 new Economic Sanctions Enforcement
Guidelines. See 74 Fed. Reg. 57,593 (Nov. 9, 2009). The Economic Sanctions Enforcement
Guidelines, as well as recent final civil penalties and enforcement information, can be
found on OFAC’s Web site at
http://www.treasury.gov/resource-center/sanctions/CivPen/Pages/civpen-index2.aspx.

ENTITIES – 31 CFR 501.805(d)(1)(i)

Ameron International Corporation Settles Potential Civil Liability for Apparent Violations
of the Iranian Transactions and Sanctions Regulations and Cuban Assets Control
Regulations: Ameron International Corporation (“Ameron”), Pasadena, CA, has agreed to pay
$434,700 to settle potential civil liability for apparent violations of the Iranian Transactions and
Sanctions Regulations, 31 C.F.R. part 560 (the “ITSR”),1

and the Cuban Assets Control
Regulations, 31 C.F.R. part 515 (the “CACR”), occurring on or about March 14, 2005, through
on or about October 5, 2006. In apparent violation of the ITSR, Ameron: (1) approved, on two
occasions, capital expenditure requests made by Ameron B.V., a Dutch subsidiary of Ameron,
and Ameron (Pte) Ltd. (“PTE”), a Singaporean subsidiary of Ameron, to purchase toolings and
other equipment needed to fulfill orders for a South Pars project, located in Iran; (2) referred to
its foreign subsidiaries three business opportunities involving the sale of goods to Iran that
Ameron itself could not have directly performed as a result of the prohibitions set forth in the
ITSR; and (3) provided testing services from its Burkburnett, Texas facility to PTE with reason
to know that they would be provided to Arvand Petrochemical, an entity located in Iran.
Furthermore, in apparent violation of the CACR, the Colombian branch office of Ameron’s U.S.
subsidiary, American Pipe & Construction International, on two occasions sold concrete pipe to
a consortium in which a Cuban company was a partner.
OFAC determined that Ameron did not voluntarily self-disclose this matter to OFAC and that the
apparent violations constitute a non-egregious case. The base penalty amount for the apparent
violations was $690,000.

The settlement amount reflects OFAC’s consideration of the following facts and circumstances,
pursuant to the General Factors under OFAC’s Economic Sanctions Enforcement Guidelines, 31
C.F.R. part 501, app. A: Ameron’s reckless disregard of U.S. sanctions requirements, including
by Ameron’s management and supervisory staff; Ameron knew, or should reasonably have
known with reasonable due diligence, that the transactions underlying the apparent violations
involved Iran or Cuba; two of the apparent violations (the approvals of the two capital